Issue of June, 2025- Decree No. 69/2024/ND-CP on Electronic Identification and Authentication

Dear Value Clients,

On June 25, 2024, the Government issued Decree No. 69/2024/ND-CP (“Decree 69”) regulating electronic identification and authentication. Accordingly, from July 1, 2025, enterprises will be required to use Electronic Identification (EID) accounts via the VNeID application to carry out online administrative procedures, replacing existing enterprise accounts on public service platforms. This represents a significant milestone in the national digital transformation roadmap, enhancing authentication efficiency, reducing administrative costs, and promoting transparency in interactions between enterprises and government authorities.

In this legal bulletin, we outline key highlights regarding Electronic Identification (EID) as applied to enterprises under the new regulations.

1.Definition of Electronic Identification (EID)

According to Article 3.1 of Decree 69, electronic identity refers to information about an enterprise within the electronic identification and authentication system that enables its unique identification in the digital environment. In simpler terms, electronic identity acts as a “digital ID card” reflecting essential details of the enterprise, including: legal representative; enterprise code; tax code; identification number; head office address; and date of establishment.[1]

This information serves not only as a basis for verifying the enterprise’s identity in administrative and legal transactions but also provides a reliable foundation for the digital system to recognize and differentiate entities with accuracy, consistency, and without duplication. Electronic Identification (EID) is the process of registering, verifying, generating, and associating electronic identity with the subject of electronic identity [2]. Once issued, the EID account carries the same legal validity as traditional physical documents during administrative procedures and electronic transactions. This marks a transformation from the use of physical papers to a unified, secure, and convenient digital identity system.

2. Registration Deadline for Enterprise EID Accounts

Currently, there is no explicit requirement mandating enterprises to register for EID accounts, nor are there penalties for non-compliance. However, under Article 40.4 of Decree 69, enterprise accounts created via the National Public Service Portal and ministerial or provincial-level administrative systems will only be valid until June 30, 2025.

From July 1, 2025, those previously issued accounts will be deactivated, and enterprises will be required to use EID accounts through the national identification application (VNeID) instead. Without an EID account on VNeID, enterprises may struggle to access useful digital services and face challenges in handling tax-related matters.

3. Procedures for Registering an Electronic Identification (EID) Account for Enterprises

Under Article 12 of Decree 69, the EID account issuance process for enterprises consists of the following steps:

Step 1: Submission

If applying remotely, the enterprise’s legal representative, head, or authorized person logs into the VNeID app using their Level-2 personal EID, selects the “Organizational Identification” feature, inputs the required information, and submits a request to establish the enterprise’s EID account—after obtaining consent from all other legal representatives (if applicable).

If applying in person, the legal representative, head of the enterprise, or authorized person completes the Request Form TK 02 (issued with Decree 69) and submits it to the competent electronic identification authority or a convenient citizen ID management office.

Step 2: Review and verification by the electronic ID authority

If the enterprise information exists in national or sectoral databases, the account issuance result will be notified within 3 working days.

If the enterprise information is not available in these databases and needs verification, the authority will notify the result within 15 days at the latest.

Step 3: Notification of registration outcome

The electronic identification authority will notify the legal representative or organizational head of the result via VNeID, registered mobile number, or email address.

If the account issuance is denied, notification will be made in writing, via SMS, or directly through the applicant’s EID account.

Note: Enterprises must activate their EID account via VNeID within 7 days of receiving the issuance notice. If the account is not activated within this period, the enterprise must contact the electronic ID authority’s hotline to complete the activation process.

4. Key Considerations in Registering EID Accounts for Enterprises

In practice, foreign-invested enterprises (FDIs) and Vietnamese enterprises with foreign legal representatives face various challenges in the EID registration process—primarily because the Ministry of Public Security’s national database has yet to fully update records for these groups. Additionally, the absence of detailed guidance and lack of synchronized coordination among state agencies has led to confusion for both authorities and enterprises.

Common obstacles include:

Foreign legal representatives are required to appear in person at the Immigration Department for verification when registering for a Level-2 EID account, posing significant difficulties for FDIs;

Legal representatives may lack personal EID accounts, or may not have completed Level-2 verification on VNeID, leading to interruptions in the registration process;

Legal information such as enterprise name, tax code, and address may not match government records due to outdated or inconsistent data across the business registration portal, social insurance systems, or tax databases.

However, foreign nationals serving as legal representatives of enterprises — particularly those in FDI enterprises — need not be overly concerned. According to Conclusion Notice of Lieutenant General Phạm The Tung, Deputy Minister of Public Security, at the working session on June 16, 2025, regarding the issuance of electronic identification for foreign nationals: “Within a 50-day period (from July 1, 2025 to August 19, 2025), the Ministry of Public Security will carry out the issuance of electronic identification for foreign nationals.”. During this time, foreign legal representatives are encouraged to visit competent authorities — such as provincial immigration departments — to complete the EID registration process. After completing the EID registration, the foreign nationals serving as legal representatives of enterprises could easily complete the EID for their enterprises.

This proactive measure demonstrates the government’s commitment to supporting enterprises in complying with Decree 69/2024/ND-CP and ensuring a smooth transition into the digital identity framework.

To facilitate a smooth EID account registration, enterprises are advised to proactively review and update all legal information. Any discrepancies should be promptly corrected with the business registration authority, tax agency, or social insurance office to ensure data consistency and accuracy.

As always, we hope you find this article helpful and look forward to working with you in the near future.

Best Regards,

ENT LAW LLC

The full version of this Legal Update can be found here.

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[1] Article 6, Decree 69.

 

[2] Article 3.3, Decree 69.

 

[3] Article 13.4, Decree 69

 

[4] Article 14.1, Decree 69.